On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, which applies to fiscal years that commence on or after December 31, 2023.
Whilst the Global Minimum Tax Law does not reflect most aspects of the OECD Administrative Guidance, the December 2024 Amendment Law did include a number of aspects. However, it did not include any of the June 2024 OECD Administrative Guidance, and certain provisions in the February 2023 Administrative Guidance did not require legislative amendments and could therefore be outlined in interpretative guidance.
The March 2025 Guidance therefore covers a number of these aspects. The Guidance is the first stage in a series of Guidance notes that will be issued, with the first two focusing on the general operation of the GloBE rules and the adjusted covered taxes calculation.
The March 2025 Guidance includes measures from the:
February 2023 OECD Administrative Guidance (AG1)
June 2024 OECD Administrative Guidance (AG4)
Implementation of OECD Administrative Guidance
| OECD Administrative Guidance | Rule | Article in Finnish Guidance |
|---|---|---|
| AG1 (February 2023) | ||
| 2.6 | Covered Taxes on deemed distributions | 7.1 |
| 2.7 | Excess Negative Tax Carry-forward guidance | 5.9.2-5.9.4 |
| 2.8 | Substitute Loss carry forwards | 5.7.3 |
| 4.1 | Deferred tax assets with respect to tax credits under Article 9.1.1 | 5.7.2/11.2 |
| 4.2 | Applicability of Article 9.1.3 to transactions similar to asset transfers | 5.7.2/11.5.4 |
| 4.3 | Asset carrying value and deferred taxes under 9.1.3 | 5.7.2/11.5.2 |
| AG4 (June 2024) | ||
| 1.2.1 | Aggregate DTL Category basis | 5.8.2 |
| 1.2.1 | Exclusion of certain types of GL accounts and separate tracking | 5.8.2 |
| 1.2.1 | Exclusion of GL accounts that generate standalone DTAs | 5.8.2 |
| 1.2.1 | Exclusion of swinging accounts and separate tracking | 5.8.2 |
| 1.2.2 | FIFO/LIFO Basis | 5.8.3 |
| 1.2.3 | Aggregation of Short-term DTLs | 5.8.3 |
| 1.2.2 | Reversal of DTLs that accrued before the Transition Year | 5.8.3 |
| 1.2.2 | 5 year unclaimed accrual election | 5.8.1 |
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | 5.7.3 |
It should be noted that the March Guidance also includes other interpretative provisions.
For instance, under the Model GloBE Rules, the amount of tax to be taken into account is based on the taxable income of the financial year recorded in the accounting result.
Section 9.1 of the Guidance clarifies that this is interpreted so that even if the tax has been recorded for the next accounting period (as tax for the previous period), it is considered part of the taxes to be taken into account for the previous period (when it is based on the determined profit or loss for the previous accounting period) providing the GloBE Information Return (GIR) has not been filed. Where tax adjustments are accounted for after the filing of the GIR, the guidance confirms that the standard rules in Article 4.6 of the Model Rules apply.
For detailed information on the application of the GloBE Rules in Finland, based on the latest Guidance, see our:
OECD Administrative Guidance: Domestic Implementation Matrix
Transitional CbCR Safe Harbour: Domestic Implementation Matrix
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